By THE MANHATTAN CONTRARIAN
Francis Menton
NYISO is the New York Independent System Operator – the nonprofit organization created to manage New York State’s electric grid. Their primary role is to ensure that sufficient electricity is generated at all times to accurately meet customer demand. Neighboring states have multi-state ISOs (e.g. PJM and ISO-NE) that do the same job, but since this is New York, we have our own.
If there’s one organization that should be vocal about New York’s ridiculous energy plans, it’s NYISO. Because if generating most of our electricity from wind and solar turns out not to work, whatever the case will be, and if the blackouts follow, whatever the case will be, NYISO will bear a large share of the blame.
So where are they? The good news is that they are slowly waking up. The bad news is that even now they are not nearly as open and loud as they should be. On October 6, they submitted a lengthy (25 page) comment on the state’s new energy plan. This comment takes the concerns expressed to a new, if still unjustifiably muted, level.
As background, New York State passed its Climate Leadership and Community Protection Act in 2019, which, among other things, mandates that 70% of electricity generation come from “renewable energy” by 2030 and 100% come from “zero-emission” sources by 2040. At the same time, New York City enacted its Local Law 97, which mandated (via complex maximum emissions formulas) that most large buildings must convert to electric heat by 2019 and 2030. Ostensibly, the state and city would enable compliance with these mandates through the construction of large quantities of wind and solar generators by developers. This process had barely started when the federal government stopped almost all grants and subsidies that had made the construction of wind and solar systems possible at the beginning of the year.
On July 25, the state’s Energy Planning Authority released its self-described “Draft Energy Plan.” It’s a “draft” because they accept comments and may even make some revisions depending on them (don’t count on them). In an August 11 post, I described the so-called plan as “hundreds of pages of nonsense” that supposedly advocates a transition to a renewables-based electricity system but lacks anything as basic as a feasibility study or cost forecast. I then made my own comment on the plan and wrote another post describing it on September 27th. Key message:
[T]The so-called “power plan” is not a power plan at all. More accurately, it would be described as the random musings and wishful thinking of some completely incompetent people who have no idea what they are doing.
With this in mind, let’s take a look at NYISO’s newly issued commentary. This sentence from page 1 is pretty representative of the overall tone:
The NYISO is submitting these comments to highlight concerns about the reliability of electrical systems and to offer approaches that support the continued reliability of electrical systems in competitive markets for consideration as part of the final state energy plan.
They provide comments to “highlight concerns.” Yes, I suspect so, but I think that is a completely inadequate representation of the problem. In fact, energy bureaucracies are pushing the state down an impossible path from which it is becoming increasingly difficult to exit before disaster strikes.
This on pages 2-3 is a bit more detailed, but still much less specific than it needs to be:
Large energy-intensive economic development projects such as semiconductor manufacturing facilities and data centers are significantly increasing electricity demand after relatively flat demand trends over the past decade. Taken together, all of these elements create uncertain conditions today, in the short term and in the long term, and any uncertainty has the real potential to have a significant impact on the reliability of electrical systems. All electrical industry stakeholders, including involved government agencies, must be aware of these concerns and incorporate them into their planning and strategy. Progress toward achieving CLCPA goals, other public policies, and providing the electricity New Yorkers need requires that the state energy plan support a well-functioning, reliable electricity sector. Reliable electricity is the foundation of the state’s plans to electrify other areas of the economy and reduce emissions. The NYISO urges the Board and NYSERDA to consider these comments and prioritize electric system reliability in the final state energy plan.
They just can’t bring themselves to say out loud that wind and solar power alone can’t reliably provide electricity to meet demand.
As you go through the comment, the statements gradually become stronger. From page 6:
Fossil fuel production remains necessary to meet consumer demand and maintain the reliability of the electricity system. The final state energy plan must include a recommendation consistent with the draft plan’s observations that combustion facilities “remain essential components of the reliability and affordability of the electric grid and decommissioning of these units will not be possible until resources are deployed that provide the same grid reliability characteristics.”
From page 8:
To maintain the reliability of the electricity system, it is not enough to simply maintain the existing fossil fuel-based power generation fleet and carefully manage the demand for these resources over the next fifteen years. The electrical system requires all existing generation resources And requires new generation resources before the current fleet suffers a catastrophic failure that endangers the health, safety and well-being of New Yorkers.
“New generation resources” are needed, but state climate law requires them to be free of carbon emissions. We are therefore talking about the magical “dispatchable emissions-free resources” (DEFRs) that will supposedly replace fossil fuel production to meet the requirements of the CLCPA. Can we somehow bring ourselves to say that these do not exist and will not exist in any relevant time frame? We come to a discussion of this topic on page 14:
The NYISO fully supports the identification and development of technologies that have the greatest potential to support the reliability of electrical systems and the requirements that will emerge as part of this energy transition. As noted in the draft plan, many of the technologies required to meet the system’s needs for firm, dispatchable capacity are not yet commercially available at scale. Development of these technologies must begin now, as these technologies must be tested and deployed on the grid before the resources that currently provide the energy consumers need and the reliability characteristics needed to support the grid can be decommissioned.
The DEFRs “are not yet commercially available on a large scale” and therefore “development…must begin now.” How lame is that? They just can’t bring themselves to say, “You have to admit that this isn’t going to happen.” With an order for tens of thousands of megawatts of these mythical generators by 2030, and it’s almost 2026, we haven’t even started “development” yet.
At least you don’t have to read between the lines of this comment to realize that the NYISO is issuing a very clear warning to the state’s energy planners. But since planners have no idea of the feasibility, cost or time frame for the availability of the necessary new resources to support the energy transition, can the NYISO say nothing more than “start development now”? What they should be saying is that this can’t work, it won’t work, and that continuing down this path is incompetent, irresponsible and dangerous.
Unlike the people in other state energy bureaucracies like NYSERDA and the Energy Planning Board, I am not suggesting that the people at NYISO lack competence. The problem, however, is that the company is organized as a non-profit organization. There is no one involved and it is unlikely that they will be held responsible for catastrophic system failures. It’s just another example of a failed socialist-lite model.
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